Good points in general but I’d add some commentary. A lot of folks I work with are just sick over the level of flaring and see it as a massive waste. They are right. But some flaring is reasonable IMO - or at least you can make a case that it is reasonable. Gas value is quite low relative to oil - so when an oil well is drilled, the massive amounts of associated gas that comes along with it doesn’t actually contribute nearly as much to the economics of the well. The gas production declines rapidly but the initial burst is very high. If all pipes going to a pad were sized for the initial burst of gas, then they’d be WAY oversized for the life of the pad. By allowing 6 mos of flaring, you allow for a more reasonable balance. However, designs of wells are also changing. Now you get about a 75% decline in well production in the first year. That means a WHOLE LOTTA gas is produced in the first 6 months. I think that dialing back flaring limits to 3 months is appropriate given this change in well design. The other challenge is that the amount of gas that is produced as associated gas isn’t fully needed in the market. The oil is the targeted products. Producers see it as a net loss to invest in the pipes necessary to get it to market because the gas value doesn’t always warrant be their targeted oil. Now if there were just one producer of all wells then you would see less Appalachian gas wells drilled and more plumbing to bring associated gas from places like the Permian to market. But instead in periods of rapid growth you see flaring as a temporary solution. My belief is that you continue to see this reigned in by states - even in places like Texas.
